In the February 2026 edition of The Record, Blue Cross Blue Shield of Michigan (BCBSM) announced a significant reimbursement policy change affecting non-preventive evaluation and management (E/M) services billed with modifier 25 when performed on the same date of service as a procedure that has a 0, 10, or 90 day global surgical period. They have since updated their policy to exclude the 90 day global surgical period, clarify that this applies to minor procedures, and define “minor procedures.” (Clarification to policy update on E/M codes appended with modifier 25)
The reimbursement reduction applies to the office/outpatient E/M codes 99202–99205 (new patients) and 99212–99215 (established patients) when appropriately appended with modifier 25 and billed with a 0 or 10 day global surgical code. Currently, BCBSM reimburses these E/M services at 100 percent of the allowed amount when billed with modifier 25 on the same day as a procedure. Under the new policy, payment for the E/M service will be reduced by half. Click on the policy link above to for more information about the scope of the policy including exclusions.
BCBSM continues to state that this change is necessary to avoid paying the practice expense component twice, once through the E/M service and again through the procedure’s global payment, which aligns with what the plan describes as industry benchmarks aimed at reducing wasteful spending. However, this rationale is based on either a misunderstanding or misrepresentation of the code valuation process and contradicts the Centers for Medicare & Medicaid Services (CMS) and the Resource Based Relative Value Scale Update Committee (RUC) which already adjusts reimbursement for procedure codes that are reported over 50 percent of the time with E/M codes to account for any overlapping costs. Because the RUC has already adjusted code valuations to account for overlap, this proposed policy change to reduce reimbursements by an additional 50 percent for E/M codes reported with modifier 25 when reported with a global surgical period constitutes a duplicative and unjustified further reduction in physician payment for legitimate, necessary services.
Policy Impact
This change affects procedural and surgical specialties, as well as medical specialties that routinely perform office-based minor procedures (see policy for BCBSM’s definition) on the same day as a separately identifiable evaluation.
- Practices that routinely provide medically necessary, separately identifiable E/M services on the same day as office-based procedures billed with the 0 or 10 day global surgical code could experience substantial revenue reductions.
- A 90-day notice posted in a provider newsletter without any advance discussion regarding the possibility of such a shift is not sufficient time for practices to be able to absorb the losses that will result from this type of policy change.
- BCBSM is undergoing a campaign around affordability, yet, this policy will result in increased costs as it will accelerate consolidation by forcing independent medical practices to close or be purchased by large health systems resulting in BCBSM paying more in facility fees and emergency department costs when patients don’t have other options in their communities. These higher fees will negate any savings from the 50 percent reduction in the new modifier 25 policy.
- Automatic E/M payment cuts tied to modifier 25 do not reliably identify inappropriate billing. Instead, documentation-based reviews of outliers and proactive education are more effective, less disruptive, and do not unfairly punish the majority of physicians and other health care professionals who appropriately code.
- Existing policy supports efficient, patient-centric quality care in a manner that meets goals of the quadruple aim related to patient and practitioner satisfaction and should be retained.
MSMS is pleased to report that we will be meeting with BCBSM in the near future to share additional information about the impact of the policy change and the fact that it ignores the established code valuation process. Additionally, on February 19, 2026, MSMS sent a formal letter with twenty-seven co-signatories to BCBSM urging the policy be rescinded before the implementation date, sharing data supporting the request, and expressing concern about the potential impact on patient access and practice sustainability.
If this policy will adversely impact your practice, we encourage you to contact BCBSM either through our grassroots advocacy website or by sending an email to James Grant, MD - Medical Director, BCBSM at Jgrant@bcbsm.com.
If you have questions or examples to share about how this change will affect your practice, please contact Dara J. Barrera, MSMS Director of Health Care Quality, Equity and Technology, at djbarrera@msms.org or 517-336-5770.